Manish Yadav vs. State of Uttar Pradesh, Supreme Court of India, Judgment dated January 22, 2025, [2025 INSC 151]
- ByPravleen Kaur --
- 15 Jun 2025 --
- 0 Comments
The Supreme Court of India in Manish Yadav vs. State of Uttar Pradesh [2025 INSC 151, decided January 22, 2025] clarified the legal distinction between a mere breach of promise to marry and a false promise made with the intent to deceive, particularly in the context of consent for sexual relations.
Facts and Background
The complainant alleged that Manish Yadav promised to marry her and, on that assurance, engaged in a sexual relationship. Later, when the marriage did not materialize, she filed a complaint alleging rape on the ground that her consent was obtained under a false promise of marriage. The trial court summoned Manish Yadav to face charges under Section 376 IPC (rape), and the High Court declined to quash the proceedings.
Legal Issues
Whether consent for sexual intercourse, given on the assurance of marriage, amounts to rape if the marriage does not occur.
The distinction between a mere breach of promise and a false promise made without intention to marry.
The evidentiary threshold for prosecuting such cases under Section 376 IPC.
Supreme Court’s Findings
The Supreme Court reiterated that consent for sexual relations must be voluntary and not based on deceit or misrepresentation. The Court drew a clear distinction between:
A breach of promise to marry (where the promise was made in good faith but could not be fulfilled due to unforeseen circumstances), and
A false promise to marry (where the accused never intended to marry and used the promise solely to obtain consent for sex).
The Court held that only in the latter scenario—where it can be shown that the accused never intended to marry at the time the promise was made—can the act amount to rape under Section 376 IPC. If the relationship was consensual and the promise was genuine at the outset, subsequent failure to marry would not constitute rape.
In Manish Yadav’s case, the Court found no evidence that the promise was false from the beginning or that there was any intent to deceive. The relationship appeared consensual, and the subsequent breakdown did not, by itself, amount to an offence under Section 376 IPC.
Conclusion
A mere breach of promise to marry does not constitute rape unless it is shown that the promise was false and made solely to obtain consent for sex.
Consent obtained under a genuine, bona fide promise, even if later unfulfilled, is not vitiated.
The Supreme Court quashed the criminal proceedings against Manish Yadav, reinforcing the need for clear evidence of deception or fraudulent intent in such cases.
RELATED Blog
0 comments